A complaint was filed against various state and county judges and officials in the United States District Court for the Western District of Missouri challenging the incarceration of a juvenile in the Laclede County Jail in Lebanon, Missouri. Evidence established that a new juvenile detention ...
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A complaint was filed against various state and county judges and officials in the United States District Court for the Western District of Missouri challenging the incarceration of a juvenile in the Laclede County Jail in Lebanon, Missouri. Evidence established that a new juvenile detention facility had been built, that juveniles were no longer kept in Laclede County Jail, and that the Missouri Supreme Court had amended the challenged rules regarding juvenile detention and detention hearings. The parties entered into a consent decree and all claims were dismissed, except one claim for injunctive relief, two claims for damages totaling $10,000, and a claim for attorney's fees. In a November 3, 1982, memorandum opinion, the U.S. District Court for the Western District of Missouri (Judge William R. Collinson) found against the plaintiff on the damages claims, finding no evidence of unconstitutional conditions of confinement or of detention without a probable cause hearing. The court also denied the request for a permanent injunction which sought to enjoin circuit judges from issuing detention orders without a probable cause hearing, or detaining juveniles in the Laclede County Jail. Because the plaintiff was therefore not a prevailing party, the court found that he was not entitled to attorney's fees.

Plaintiff later filed a motion for relief from final judgment, which was denied because the motion had been filed after the time to appeal or request relief had expired. Plaintiff appealed the denial of this relief to the United States Court of Appeals for the Eighth Circuit; it was undisputed that while the Clerk of the District Court did mail copies of the memorandum opinion to all parties, he neglected to mail notice of entry of the judgment to the parties. The U.S. Court of Appeals for the Eighth Circuit (Judge John R. Gibson) found that the memorandum opinion constituted a final judgment, and that the lack of notice of entry by the clerk did not affect the time to file for relief. L.Z. v Parrish, 733 F.3d 585 (8th Cir. 1984). Furthermore, the court found that plaintiff's attorneys, in waiting 77 days to inquire as to whether judgment had been entered, had not displayed diligence in attempting to discover the status of the case, making reversal of the district's courts denial of relief inappropriate.